9911796707
TMI Blog1987 (7) TMI 2X X X X Extracts X X X X X X X X Extracts X X X X ..... This was the second year of the assessee's new project at Vidyanagar going into production. On March 19, 1965, the Income-tax Officer computed the assessment under section 143(3) of the Act after determining the rebate admissible under sections 84 and 101 of the Act at Rs. 2,72,372. He reopened the assessment under section 147(b) of the Act and by his reassessment order dated November 29, 1966, recomputed the rebate at Rs. 2,51,222. The appeal by the assessee to the Appellate Assistant Commissioner was dismissed. The Appellate Tribunal, on further appeal by the assessee, came to hold that : " There is considerable force in the arguments urged by Sri Talati. In view of the phraseology used in the rules, we are inclined to accept Sri Talati' ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he case of assets acquired by purchase and entitled to depreciation (i) if they have been acquired before the computation period, their written down value on the commencing date of the said period; (ii) if they have been acquired on or after the commencing date of the computation period, their average cost during the said period ; (b) in the case of assets acquired by purchase and not entitled to depreciation (i) if they have been acquired before the computation period, their actual cost to the assessee ; (ii) if they have been acquired on or after the commencing date of the computation period, their average cost during the said period ; ... (3) Any borrowed money and debt due by the person carrying on the business shall be deducted and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 40,10,947. To this figure was added a sum of Rs. 1,39,764 on account of depreciation as on January 1, 1963, as also on account of the average value of additions. The other assets were valued under rule 19(1)(b) at Rs. 44,38,126 as on January 1, 1963. All put together, the aggregate valuation came to Rs. 85,88,837. From this aggregate, deduction of a sum of Rs. 44,01,803 representing loans, other liabilities including provision for tax as authorised by rule 19 was made leaving the valuation of the capital at Rs. 41,87,034. To this figure, the sum of Rs. 3,52,503 being half of the profit from the new project was added to compute the value at Rs.45,39,537. Following the provision of section 84 of the Act, entitlement to exemption was determine ..... X X X X Extracts X X X X X X X X Extracts X X X X
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